RESPONDENT: United States
LOCATION: United States District Court for the Eastern District of Michigan
DOCKET NO.: 87-6
DECIDED BY: Rehnquist Court (1988-1990)
CITATION: 485 US 681 (1988)
ARGUED: Mar 23, 1988
DECIDED: May 02, 1988
Don Ferris - For the Petitioner
William C. Bryson - For the United States
Facts of the case
Between April 11 and April 15, 1985, a trailer containing 32,000 blank videocassette tapes was stolen from an Overnight Express yard in South Holland, Illinois. On April 17, 1985, Guy Rufus Huddleston contacted a business owner in Michigan and offered to sell her a large number of blank videocassette tapes for significantly under market value. Huddleston was later charged with possessing and selling stolen videocassette tapes across state lines. At trial, the government presented evidence that Huddleston had previously trafficked in stolen goods. In response, Huddleston argued that he had not known any of the goods were stolen. The district court then instructed the jury that the evidence of prior bad acts could only be used to establish Huddleston’s knowledge, not to prove his character. The jury convicted Huddleston for possession of stolen goods.
The U.S. Court of Appeals for the Sixth Circuit initially reversed the conviction and held that the government failed to prove by clear and convincing evidence that the goods in the prior instances were in fact stolen. The Court of Appeals granted a rehearing and subsequently affirmed the conviction, holding that the government only needs to meet a preponderance of the evidence standard.
Must a court make a preliminary ruling on whether the prosecution has proven that the defendant is guilty of “similar acts” by a preponderance of the evidence before submitting such character evidence to the jury?
Media for Huddleston v. United StatesAudio Transcription for Oral Argument - March 23, 1988 in Huddleston v. United States
Audio Transcription for Opinion Announcement - May 02, 1988 in Huddleston v. United States
William H. Rehnquist:
I have the opinion of the Court to announce in No. 87-6 Huddleston against United States.
This case involves the rules under which evidences admitted at trial under federal courts.
The defendant in this criminal case, Guy Rufus Huddleston was charged with possessing and selling stolen video cassette tapes in interstate commerce.
The only real question at his trial was whether he knew the tapes were stolen.
To prove this, the government sought to introduce an evidence at trial similar acts including evidence that Huddleston had previously sold for $28 purportedly new television sets were -- which were supplied to him by the same source that supplied the video tapes involved in this case.
The government's theory of relevance was that the television sets were stolen, and proof that Huddleston had engaged in other sales of stolen merchandise from the same suspicious source, would be strong evidence that he knew that the cassette tapes were stolen as well.
The District Court admitted the evidence under Federal Rule of evidence, 404(b) and the Court of Appeals for the Sixth Circuit affirmed the conviction.
In an opinion filed with the clerk today, we affirm the judgment of the Court of Appeals.
Contrary to the claim of the defendant, we hold that a trial court need not make its own preliminary finding that the similar act actually happened before it admits evidence to this effect.
Similar act of evidence they -- may be admitted so long as the jury can reasonably conclude that these similar acts occurred, and so long as it complies with the general provisions of the rules such as those requiring a balancing of the relevance of the evidence against the possible prejudice.
In this case, the jury reasonably could have concluded that the defendant had previously sold stolen television sets and was entitled to weigh that fact against him in determining whether the video cassette tapes involved in this case had been stolen.
The opinion of the Court is unanimous.